NL-08-0765, Submittal of Relief Requests Second 10-Year Interval Inservice Inspection Program

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Submittal of Relief Requests Second 10-Year Interval Inservice Inspection Program
ML081510904
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 05/30/2008
From: David Jones
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-0765
Download: ML081510904 (53)
v • d • e


Text

David H. Jones Southern Nuclear Vice President Operating Company. Inc.

Engineering 40 Inverness Center Parkway Birmingham, Alabama 35242 Tel 205.992.5984 Fax 205.992.0341 SOUIHE-A COMPANY May 30.2008 Energy to Serve lOur WorM'"

Docket Nos.: 50-424 NL-08-0765 50-425 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington. D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Intervallnservice Inspection Program Submittal of Relief Requests Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(g)(5)(iv), Southern Nuclear Operating Company hereby submits the enclosed relief requests for the Vogtle Electric Generating Plant - Units 1 and 2, Second 10-Year Intervallnservice Inspection Program.

These relief requests are coverage relief requests where it is impractical to obtain more than 90 percent coverage and there is reasonable assurance of structural integrity. Two of the nine relief requests pertain to pipe weld examinations performed after the implementation of risk informed inservice inspection (RI-ISI).

The relief requests are requested to be approved by May 29. 2009.

This letter contains no NRC commitments. If you have any questions, please advise.

DHJ/DRG/daj

U. S. Nuclear Regulatory Commission NL-08-0765 Page 2

Enclosures:

1. RR-43, Vogtle - Units 1 and 2 Pressurizer Nozzle to Safe-End Welds
2. RR-44, Vogtle - Unit 1 Class 1 Cast Stainless Piping Butt Welds
3. RR-45, Vogtle - Units 1 and 2 Class 1 Stainless Steel Piping Butt Welds
4. RR-46, Vogtle - Unit 2 Class 2 Stainless Steel Piping Butt Welds
5. RR-47, Vogtle - Units 1 and 2 Class 1 and 2 Stainless Steel Piping Butt Welds (RI-ISI)
6. RR-48, Vogtle - Unit 2 Class 2 Ferritic Steel Piping Butt Welds (RI-ISI)
7. RR-49, Vogtle - Units 1 and 2 Reactor Pressure Vessel Shell and Bottom Head Welds
8. RR-50, Vogtle - Units 1 and 2 Class 2 Vessel Weld Examinations
9. RR-51, Vogtle - Units 1 and 2 Class 2 Residual Heat Removal Heat Exchanger Shell Welds cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President - Vogtle RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 1 Relief Request RR-43 Pressurizer Nozzle to Safe-End Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-43 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Units 1 and 2.

Interval -

Interval Dates:

2nd ISI Interval - May 31, 1997 through May 30, 2007.

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the Date for code or addenda is determined to be impractical by the licensee and is not Approval and included in the revised inservice inspection program as permitted by paragraph Basis: (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 1, ASME Section XI Category B-F, Item B5.40, pressure retaining Components Affected: dissimilar metal piping welds on the pressurizer as shown in Table RR-43.

Applicable ASME Section XI, 1989 Edition with no addenda. These were pre-Appendix Code Edition and Addenda: VIII examinations.

Applicable Examination Category B-F, Table IWB-2500-1, of the 1989 Edition of the ASME Code Section XI Code requires surface and volumetric examination of pressure-Requirements: retaining dissimilar welds in Class 1 piping. Applicable examination volumes are shown in ASME Section XI, Figure IWB-2500-8 and include essentially 100% of the weld length. To obtain 100% coverage, the ultrasonic beam must pass through the entire examination volume in four directions, axial (up &

down) and circumferential (clockwise & counter-clockwise). Supplement 4 of Appendix III adds an additional 1/2-inch of base material on the ID for reflectors transverse to the weld (see Figure RR-43 for a pictorial representation).

Impracticality Physical limitations due to geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWB-Compliance: 2500-8 and ASME Section XI Appendix III, Supplement 4. The eight welds with limitations are described in Table RR-43. Figure RR-43 shows a typical representation of a single-side access examination, along with limitations. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing pressurizer nozzles and Caused by safe ends with new components fabricated with a special design to allow Compliance: examination.

E1-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-43 Version 1.0 Proposed A surface examination (liquid penetrant technique) was performed on these Alternative welds. The ultrasonic examinations were performed to Appendix III and and Basis for consisted of primarily a single-sided examination from the safe-end side of the Use: weld. The ultrasonic examination was also performed from the nozzle side to the extent possible.

Visual VT-2 examinations associated with the Class 1 leakage test were performed each refueling outage at both units. A bare metal visual (BMV) examination, in accordance with Materials Reliability Program MRP-139, was performed on the Vogtle-1 welds during the 1R12 and 1R13 outages (Spring 2005 and Fall 2006 outages, respectively) and during the Fall 2005 refueling outage (2R11). During the Spring 2008 outage (1R14) and the Spring 2007 outage (2R12), full-structural weld overlays were installed on the pressurizer nozzle to safe end welds for each Vogtle unit. In addition to mitigating these welds, the design of the full structural weld overlays allows future ultrasonic examinations to be performed with essentially no physical limitations.

Based on the level of examination coverage obtained for the subject welds plus the Vogtle decision to install full structural weld overlays on all six pressurizer nozzles for both units, there is reasonable assurance of the structural integrity of these welds. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief The proposed relief request is applicable for the 2nd Interval.

Request:

Precedents: Ultrasonic coverage is similar to that shown in Vogtle-1 RR-12 and Vogtle-2 RR-12 for the first ISI interval.

References:

None Status: Awaiting NRC approval.

E1-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-43 Version 1.0 TABLE RR-43 Examination Identification No. Description Limitation Coverage Results 11201-V6-002-W17 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 1R9 (Fall 2000 Outage) End nozzle side due to the configuration. Limited circumferential Indications scans on the nozzle side looking for axial cracking due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

11201-V6-002-W18 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 1R9 (Fall 2000 Outage) End nozzle side due to the configuration. Limited circumferential Indications scans on the nozzle side looking for axial cracking due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

11201-V6-002-W19 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 1R9 (Fall 2000 Outage) End nozzle side due to the configuration. Limited circumferential Indications scans on the nozzle side looking for axial cracking due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

11201-V6-002-W20 6-Inch Relief Pre-PDI examination. UT scans looking for circumferential 100% PT UT Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Indications 1R9 (Fall 2000 Outage) End nozzle side due to the configuration. Limited circumferential due to scans on the nozzle side looking for axial cracking due to the Geometry configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

E1-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-43 Version 1.0 TABLE RR-43 Examination Identification No. Description Limitation Coverage Results 21201-V6-002-W17 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 2R8 (Spring 2001 Outage) End nozzle side to the configuration. Limited circumferential scans Indications on the nozzle side due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

21201-V6-002-W18 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 2R8 (Spring 2001 Outage) End nozzle side to the configuration. Limited circumferential scans Indications on the nozzle side due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

21201-V6-002-W19 6-Inch Safety Pre-PDI examination. UT scans looking for circumferential 100% PT A Code-Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT allowable PT 2R8 (Spring 2001 Outage) End nozzle side to the configuration. Limited circumferential scans indication; on the nozzle side due to the configuration of the nozzle. See No Figure RR-43 for typical picture and coverage. Recordable UT indications 21201-V6-002-W20 6-Inch Relief Pre-PDI examination. UT scans looking for circumferential 100% PT No Nozzle to Safe cracking was 100% from the safe-end side but limited on the 69% UT Recordable 2R8 (Spring 2001 Outage) End nozzle side to the configuration. Limited circumferential scans Indications on the nozzle side due to the configuration of the nozzle. See Figure RR-43 for typical picture and coverage.

E1-4

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-43 Version 1.0 FIGURE RR-43 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

CL Pipe/Elbow Component (2) (1) (2)

.25 .25 (1) Examination volume: Weld + 1/4 each side of weld toes.

(2) Examination volume: Weld + 1/2 each side of weld toes for austenitic transverse scans.

E1-5

Vogtle Electric Generating Plant - Unit 1 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 2 Relief Request RR-44 Class 1 Cast Stainless Piping Butt Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-44 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Unit 1.

Interval -

Interval Dates:

2nd ISI Interval - May 31, 1997 through May 30, 2007.

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the Date for code or addenda is determined to be impractical by the licensee and is not Approval and included in the revised inservice inspection program as permitted by paragraph Basis: (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 1, ASME Section XI Category B-J, Item B9.11, austenitic steel piping Components Affected: welds as shown in Table RR-44.

Applicable ASME Section XI, 1989 Edition with no addenda. These were pre-Appendix Code Edition and Addenda: VIII examinations.

Applicable Examination Category B-J, Table IWB-2500-1, of the 1989 Edition of the ASME Code Section XI Code requires surface and volumetric examination of pressure-Requirements: retaining welds in Class 1 piping. Applicable examination volumes are shown in ASME Section XI, Figure IWB-2500-8 and include essentially 100% of the weld length. To obtain 100% coverage, the ultrasonic beam must pass through the entire examination volume in four directions, axial (up & down) and circumferential (clockwise & counter-clockwise). Supplement 4 of Appendix III adds an additional 1/2-inch of base material on the ID for reflectors transverse to the weld (see Figure RR-44 for a pictorial representation).

Impracticality Physical limitations due to the geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWB-Compliance: 2500-8 and ASME Section XI Appendix III, Supplement 4. Two cast stainless piping welds with limitations are described in Table RR-44. Figure RR-44 shows a typical representation of a single-side access examination, along with limitations. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing reactor coolant pump Caused by nozzles with new components fabricated with a special design to allow Compliance: examination.

E2-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-44 Version 1.0 Proposed A surface examination (liquid penetrant technique) was performed on these Alternative welds. The ultrasonic examinations were performed to Appendix III and and Basis for consisted of primarily a single-sided examination from the pipe or elbow side of Use: the weld. The ultrasonic examination was also performed from the nozzle side to the extent possible. Based on the level of examination coverage obtained for the subject welds, if significant service-induced degradation were occurring, there is reasonable assurance that evidence of it would have been detected. In addition, VT-2 visual examinations associated with the Class 1 leakage test were performed each refueling outage. These examinations and tests provide reasonable assurance of the structural integrity of these welds. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief The proposed relief request is applicable for the 2nd Interval.

Request:

Precedents: This relief request is essentially identical to Vogtle RR-13, Revision 3 for the 2nd ISI interval which was approved by the NRC on June 20, 2001.

References:

NRC SER TAC Nos. MB0603 and MB0604.

Status: Awaiting NRC approval.

E2-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-44 Version 1.0 TABLE RR-44 Identification No. / Exam. Examination History Description Limitation Coverage Results 11201-005-8 31 Elbow to Nozzle 100 % surface examination. Complete ultrasonic 100% PT No examination from the elbow side. Limited coverage 90% UT Recordable 1R8 (Spring 1999 Outage) for axial and circumferential flaws from the nozzle Indications side due to configuration. See Figure RR-44 for typical picture and coverage.

11201-009-1 27.5 Nozzle to Pipe 100 % surface examination. Complete ultrasonic 100% PT No examination from the pipe side. Limited coverage for 75% UT Recordable 1R8 (Spring 1999 Outage) axial and circumferential flaws from the nozzle side Indications due to configuration. See Figure RR-44 for typical picture and coverage.

E2-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-44 Version 1.0 FIGURE RR-44 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

(1) Examination volume: Weld + 1/4 each side of weld toes.

(2) Examination volume: Weld + 1/2 each side of weld toes for austenitic transverse scans.

E2-4

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 3 Relief Request RR-45 Class 1 Stainless Steel Piping Butt Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-45 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Units 1 and 2.

Interval -

Interval Dates:

2nd ISI Interval-May 31, 1997 through May 30, 2007.

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the Date for code or addenda is determined to be impractical by the licensee and is not Approval and included in the revised inservice inspection program as permitted by paragraph Basis: (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 1, ASME Section XI Category B-J, Item B9.11, austenitic steel piping Components Affected: welds as shown in Table RR-45.

Applicable Code Edition ASME Section XI, 1989 Edition with no addenda.

and Addenda:

Applicable Examination Category B-J, Table IWB-2500-1, of the 1989 Edition of the ASME Code Section XI Code requires both a surface and a volumetric examination. The Requirements: examinations were performed after the required implementation of Supplement 2 of Appendix VIII. The examination volumes are shown in ASME Section XI Figure IWB-2500-8 and include essentially 100% of the weld length.

Impracticality Physical limitations due to geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWB-2500-Compliance: 8. The two welds with limitations are described in Table RR-45. Figure RR-45 shows a typical representation of a single-side access examination with a valve, along with limitations. The configuration of the flange is similar. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing valve and flange with Caused by Compliance: new components fabricated with a special design to allow examination.

Proposed A surface examination (liquid penetrant technique) was performed on these Alternative welds. The ultrasonic examinations were performed after Appendix VIII and and Basis for consisted of a single-sided examination from the pipe or elbow side of the weld.

Use: The root of the weld was interrogated with both a 45° shear wave and a 60° E3-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-45 Version 1.0 refracted longitudinal wave looking for circumferential cracking. In addition, VT-2 visual examinations associated with the Class 1 leakage test are performed each refueling outage. These examinations and tests provide reasonable assurance of structural integrity of these welds. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief The proposed relief request is applicable for the 2nd Interval.

Request:

Precedents: The physical limitations described in this relief request are essentially identical to Vogtle RR-13, Revision 3 for the 2nd ISI interval which was approved by the NRC on June 20, 2001. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the coverage calculations are less than the typical pre-Appendix VIII examinations listed in RR-13, Revision 3.

References:

NRC SER TAC Nos. MB0603 and MB0604.

Status: Awaiting NRC approval.

E3-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-45 Version 1.0 Table RR-45 Identification No. / Examination Exam. History Description Limitation Coverage Results 11204-021-17 6 Valve to Pipe Post-PDI examination. 100% surface examination. 100% PT No Complete ultrasonic examination from the pipe side. No 50% UT Recordable 1R10 (Spring 2002 Outage) examination coverage from the valve side due to Indications configuration. See Figure RR-45 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

21201-058-7 6 Elbow to Flange Post-PDI examination. 100% surface examination. 100% PT No Complete ultrasonic examination from the elbow side. No 50% UT Recordable 2R8 (Spring 2001 Outage) examination coverage from the flange side due to Indications configuration. See Figure RR-45 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

E3-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-45 Version 1.0 FIGURE RR-45 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

C L

Pipe/Elbow Component (1)

(1) Examination volume: Weld + 1/4 each side of weld toes.

Weld E3-4

Vogtle Electric Generating Plant - Unit 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 4 Relief Request RR-46 Class 2 Stainless Steel Piping Butt Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-46 Version 1.0 Plant Site- Vogtle Electric Generating Plant - Unit 2.

Unit:

Interval - 2nd ISI Interval-May 31, 1997 through May 30, 2007.

Interval Dates:

10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the code or addenda is determined to be impractical by the licensee and is not included in the revised inservice inspection program as permitted by paragraph Requested (g)(4) of this section, the basis for this determination must be demonstrated to Date for the satisfaction of the Commission not later than 12 months after the expiration Approval and of the initial 120-month period of operation from start of facility commercial Basis: operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 2, ASME Section XI Category C-F-1, Item Number C5.11, austenitic steel Components piping welds as shown in Table RR-46.

Affected:

Applicable ASME Section XI, 1989 Edition with no addenda.

Code Edition and Addenda:

Applicable Examination Category C-F-1, Table IWC-2500-1, of the 1989 Edition of the Code ASME Section XI Code requires both a surface and a volumetric examination.

Requirements: The examinations were performed after the required implementation of Supplement 2 of Appendix VIII. The examination volumes are shown in ASME Section XI Figure IWC-2500-7(a) and include essentially 100% of the weld length.

Impracticality Physical limitations due to geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWC-Compliance: 2500-7(a). The two welds with limitations are described in Table RR-46.

Figure RR-46 shows a typical representation of a single-side access examination with a valve, along with limitations. The configuration of the flange is similar. The examinations were performed to the maximum extent possible.

Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing flanges with new Caused by components fabricated with a special design to allow examination.

Compliance:

Proposed A surface examination (liquid penetrant technique) was performed on these Alternative welds. The ultrasonic examinations were performed after the implementation of and Basis for Appendix VIII and consisted of primarily a single-sided examination from the E4-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-46 Version 1.0 Use: pipe side of the weld. The root of the weld was interrogated with both a 45° shear wave and a 60° refracted longitudinal wave looking for circumferential cracking. In addition, VT-2 visual examinations associated with the Class 2 leakage test are performed once every ISI period. These examinations and tests provide reasonable assurance of structural integrity of these welds.

Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of The proposed relief request is applicable for the 2nd Interval.

Proposed Relief Request:

Precedents: The physical limitations described in this relief request are essentially identical to Vogtle RR-15, Revision 3 for the 2nd ISI interval which was approved by the NRC on June 20, 2001. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the coverage calculations are less than the typical pre-Appendix VIII examinations listed in RR-15, Revision 3.

References:

NRC SER TAC Nos. MB0603 and MB0604.

Status: Awaiting NRC approval.

E4-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-46 Version 1.0 Table RR-46 Identification No. / Examination Exam. History Description Limitation Coverage Results 21206-005-1 8 Flange to Pipe Post-PDI examination. 100% surface examination. Complete 100% PT No ultrasonic examination from the pipe side. No examination 50% UT Recordable 2R8 (Spring 2001 Outage) coverage from the flange side due to configuration. See Indications Figure RR-46 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

21206-006-1 8 Flange to Pipe Post-PDI examination. 100% surface examination. Complete 100% PT No ultrasonic examination from the pipe side. No examination 50% UT Recordable 2R8 (Spring 2001 Outage) coverage from the flange side due to configuration. See Indications Figure RR-46 for typical picture and coverage.

Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

E4-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-46 Version 1.0 FIGURE RR-46 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

C L

Pipe/Elbow Component (1)

(1) Examination volume: Weld + 1/4 each side of weld toes.

Weld E4-4

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 5 Relief Request RR-47 Class 1 and 2 Stainless Steel Piping Butt Welds (RI-ISI)

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Units 1 and 2.

Interval -

Interval Dates:

2nd ISI Interval-May 31, 1997 through May 30, 2007.

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the Date for code or addenda is determined to be impractical by the licensee and is not Approval and included in the revised inservice inspection program as permitted by paragraph Basis: (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Southern Nuclear (SNC) developed the risk-informed ISI (RI-ISI) program for Components piping welds during the second ISI interval for Vogtle. SNC determined a Affected: scope from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI-ISI was implemented at Vogtle during the 1R11 outage in Fall 2003 for Unit-1 and the 2R10 outage in Spring 2004 for Unit-2. The selected RI-ISI examinations are assigned ASME Category R-A per the Vogtle alternative.

Vogtle has revised the original pipe weld numbers by adding an -RI suffix onto the weld numbers to distinguish them from the previous ISI weld number.

The affected components are Class 1 and 2, ASME Section XI Category R-A, austenitic steel piping welds as shown in Tables RR-47-1 and -2, respectively.

Applicable ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical Code Edition and Addenda: alternative to implement risk-informed ISI for the examination of piping welds.

Applicable The Vogtle RI-ISI documentation including the technical alternative is used to Code determine the scope of the volumetric examinations. The examinations were Requirements: performed after the required implementation of Supplement 2 of Appendix VIII.

The examination volumes typically follow ASME Section XI Figures IWB-2500-8 and IWC-2500-7(a) except that the volume was increased to include 1/2-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

Impracticality Physical limitations due to the geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figures IWB-Compliance: 2500-8 and IWC-2500-7(a). The thirteen welds with limitations are described in Table RR-47-1 (for Class 1 piping) and Table RR-47-2 (for Class 2 piping). The examinations were performed to the maximum extent possible. Figure RR-47 shows a typical representation of a single-side access examination with a E5-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 valve, along with limitations. The configuration of the branch connections are similar. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing valves and branch Caused by connections with new components fabricated with a special design to allow Compliance: examination.

Proposed The ultrasonic examinations were performed after PDI implementation and Alternative consist of primarily a single-sided examination from the pipe or elbow side of and Basis for the weld. All fourteen welds received a 45° shear wave examination looking for Use: circumferential and axial cracking. The thicker piping welds (i.e., greater than 0.5-inch) were also examined with a 60° refracted longitudinal wave. The thinner piping welds were examined with a 70° shear wave. The prescribed coverage for the ultrasonic examinations is 50 %. In addition, VT-2 visual examinations associated with the Class 1 leakage test are performed each refueling outage for the welds listed in Table RR-47-1 and each ISI period for the welds listed in Table RR-47-2. These examinations and tests provide reasonable assurance of structural integrity of these welds. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief The proposed relief request is applicable for the 2nd Interval.

Request:

Precedents: The physical limitations described in this relief request are essentially identical to Vogtle RR-13, Revision 3 and RR-15, Revision 3 for the 2nd ISI interval which was approved by the NRC on June 20, 2001. Since the UT examinations in this relief request were performed to Supplement 2 of Appendix VIII, the coverage calculations are less than the typical pre-Appendix VIII examinations listed in RR-13 and RR-15.

References:

NRC SER TAC Nos. MB0603 and MB0604 for the previous relief requests.

The NRC approved risk-informed ISI at Vogtle per SER TAC Nos. MB6118 and MB6119.

Status: Awaiting NRC approval.

E5-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Table RR-47-1: Class 1 Piping Welds Examination Identification No. Description Limitation Coverage Results 11204-021-16-RI 6 Pipe to Valve Post-PDI examination. Complete ultrasonic examination from 50% UT UT Indication the pipe side. No examination coverage from the valve side due due to 1R12 (Spring 2005 Outage) to configuration. See Figure RR-47 for typical picture and Geometry coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

11204-023-15-RI 6 Pipe to Valve Post-PDI examination. Limited ultrasonic examination from the 40% UT No pipe side. No examination coverage from the valve side due to Recordable 1R11 (Fall 2003 Outage) configuration. See Figure RR-47 for typical picture and Indications coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited. Also, the pipe side had an additional limitation due to support steel interference which reduced the overall coverage to 40%.

21204-021-16-RI 6 Pipe to Valve Post-PDI examination. Complete ultrasonic examination from 50% UT UT Indication the pipe side. No examination coverage from the valve side due due to 2R10 (Spring 2004 Outage) to configuration. See Figure RR-47 for typical picture and Geometry coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

E5-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Table RR-47-1: Class 1 Piping Welds Examination Identification No. Description Limitation Coverage Results 21204-023-15R-RI 6 Pipe to Valve Post-PDI examination. Baseline examination after valve 35% UT No replacement. Complete ultrasonic examination from the pipe Recordable 2R12 (Spring 2007 Outage) side for circumferential flaws. No examination coverage from the Indications valve side due to configuration. Limited ultrasonic examination for clockwise and counterclockwise scans (for axial flaws) on the weld due to the taper. See Figure RR-47 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited. However, with the additional limitations for the clockwise and counterclockwise scans the overall coverage is reduced to 35%.

21204-023-16R-RI 6 Valve to Pipe Post-PDI examination. Baseline examination after valve 35% UT No replacement. Complete ultrasonic examination from the pipe Recordable 2R12 (Spring 2007 Outage) side for circumferential flaws. No examination coverage from the Indications valve side due to configuration. Limited ultrasonic examination for clockwise and counterclockwise scans (for axial flaws) on the weld due to the taper. See Figure RR-47 for typical picture and coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited. However, with the additional limitations for the clockwise and counterclockwise scans the overall coverage is reduced to 35%.

E5-4

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Table RR-47-2: Class 2 Piping Welds Identification No. / Examination Exam. History Description Limitation Coverage Results 11204-038-1-RI 14 Branch Post-PDI examination. Complete ultrasonic examination from the 50% UT No Connection to Pipe pipe side. No examination coverage from the branch connection Recordable 1R11 (Fall 2003 Outage) side due to configuration. See Figure RR-47 for typical picture and Indications coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

11204-063-28-RI 4 Valve to Pipe Post-PDI examination. Complete ultrasonic examination from the 50% UT No pipe side. No examination coverage from the valve side due to Recordable 1R11 (Fall 2003 Outage) configuration. See Figure RR-47 for typical picture and coverage. Indications Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50%

of the Code coverage can be credited.

11204-177-13-RI 8 Pipe to Valve Post-PDI examination. Complete ultrasonic examination from the 50% UT No pipe side. No examination coverage from the valve side due to Recordable 1R11 (Fall 2003 Outage) configuration. See Figure RR-47 for typical picture and coverage. Indications Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50%

of the Code coverage can be credited.

E5-5

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Table RR-47-2: Class 2 Piping Welds Identification No. / Examination Exam. History Description Limitation Coverage Results 11204-192-4-RI 8 Pipe to Branch Post-PDI examination. Complete ultrasonic examination from the 50% UT No Connection pipe side. No examination coverage from the branch connection Recordable 1R11 (Fall 2003 Outage) side due to configuration. See Figure RR-47 for typical picture and Indications coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

21204-006-2-RI 24 Valve to Elbow Post-PDI examination. Complete ultrasonic examination from the 50% UT UT elbow side. No examination coverage from the valve side due to Indications 2R11 (Fall 2005 Outage) configuration. See Figure RR-47 for typical picture and coverage. due to Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both Geometry sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50%

of the Code coverage can be credited.

21204-008-10-RI 8 Pipe to Valve Post-PDI examination. Complete ultrasonic examination from the 50% UT No pipe side. No examination coverage from the valve side due to Recordable 2R10 (Spring 2004 configuration. See Figure RR-47 for typical picture and coverage. Indications Outage) Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50%

of the Code coverage can be credited.

E5-6

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 Table RR-47-2: Class 2 Piping Welds Identification No. / Examination Exam. History Description Limitation Coverage Results 21204-039-1-RI 6 Valve to Pipe Post-PDI examination. Complete ultrasonic examination from the 50% UT No pipe side. No examination coverage from the valve side due to Recordable 2R10 (Spring 2004 configuration. See Figure RR-47 for typical picture and coverage. Indications Outage) Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50%

of the Code coverage can be credited.

21204-192-4-RI 8 Pipe to Branch Post-PDI examination. Complete ultrasonic examination from the 50% UT No Connection pipe side. No examination coverage from the branch connection Recordable 2R10 (Spring 2004 side due to configuration. See Figure RR-47 for typical picture and Indications Outage) coverage. Per 10 CFR 50.55a(b)(2)(xv)(A)(2) when examination from both sides is not possible on austenitic welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld. Since PDI qualifications do not meet requirements for flaws on the opposite side of the weld, only 50% of the Code coverage can be credited.

E5-7

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-47 Version 1.0 FIGURE RR-47 Typical Single-Side Access for Volumetric Examinations Limited examination area (i.e., not all four-directional coverage) shown as hatched.

C L

Pipe/Elbow Component (1)

(1) Examination volume: Weld + 1/4 each side of weld toes.

Weld E5-8

Vogtle Electric Generating Plant - Unit 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 6 Relief Request RR-48 Class 2 Ferritic Steel Piping Butt Welds (RI-ISI)

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-48 Version 1.0 Plant Site- Vogtle Electric Generating Plant - Unit 2.

Unit:

Interval - 2nd ISI Interval-May 31, 1997 through May 30, 2007.

Interval Dates:

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by the Date for code or addenda is determined to be impractical by the licensee and is not Approval and included in the revised inservice inspection program as permitted by paragraph Basis: (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Southern Nuclear (SNC) developed the risk-informed ISI (RI-ISI) program for Components piping welds during the second ISI interval for Vogtle. SNC determined a Affected: scope from the Class 1 and 2 piping and prepared a technical alternative for NRC review. The NRC approved the technical alternative (see References) and RI-ISI was implemented at Vogtle during the 1R11 outage in Fall 2003 for Unit-1 and the 2R10 outage in Spring 2004 for Unit-2. The selected RI-ISI examinations are assigned ASME Category R-A per the Vogtle alternative.

Vogtle has revised the original pipe weld numbers by adding an -RI suffix onto the weld numbers to distinguish them from the previous ISI weld number.

The affected component is a Class 2, ASME Section XI Category R-A, ferritic steel piping weld as shown in Table RR-48.

Applicable ASME Section XI, 1989 Edition with no Addenda plus NRC-approved technical Code Edition alternative to implement risk-informed ISI for the examination of piping welds.

and Addenda:

Applicable The Vogtle RI-ISI documentation including the technical alternative is used to Code determine the scope of the volumetric examinations. The examinations were Requirements: performed after the required implementation of Supplement 3 of Appendix VIII.

The examination volume is shown in ASME Section XI, Figure IWC-2500-7(a) except that the volume was increased to include 1/2-inch beyond each side of the base metal thickness transition (or counterbore) to meet RI-ISI requirements.

Impracticality Physical limitations due to the geometric configuration of the welded areas of restricted coverage of the examination volume as required by Figure IWC-Compliance: 2500-7(a). The weld with limitations is described in Table RR-48. The examination was performed to the maximum extent possible. Figure RR-48 shows a typical representation of the 29.5-inch weld, along with limitations.

Appreciably increasing coverage was impractical due to the limitations E6-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-48 Version 1.0 described in the table.

Burden Compliance would require replacement of the existing 29.5-inch manifold piping Caused by plus the valve with new components fabricated with a special design to allow Compliance: examination.

Proposed The ultrasonic examinations were performed after the implementation of Alternative Appendix VIII and consist of primarily a single-sided examination from the and Basis for manifold piping. The root area of the weld was interrogated with a 45° shear Use: wave looking for circumferential cracking. In addition, VT-2 visual examinations are performed each ISI period for the weld listed in Table RR-48. These examinations and tests provide reasonable assurance of structural integrity of this weld. Therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of The proposed relief request is applicable for the 2nd Interval.

Proposed Relief Request:

Precedents: The physical limitations described in this relief request are essentially identical to Vogtle RR-16, Revision 1 for the 2nd ISI interval which was approved by the NRC on December 31, 1998. Since the UT examination in this relief request were performed to Supplement 3 of Appendix VIII, the coverage calculations are less than the typical pre-Appendix VIII examinations listed in RR-16, Revision 1.

References:

NRC SER TAC Nos. M98977, M98978, MA3364 and MA3365 for the previous relief requests. The NRC approved risk-informed ISI at Vogtle per SER TAC Nos. MB6118 and MB6119.

Status: Awaiting NRC approval.

E6-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-48 Version 1.0 Table RR-48: Class 2 Piping Welds Examination Identification No. Description Limitation Coverage Results 21301-004-10-RI 29.5-Inch Manifold Post-PDI examination after the implementation of RI-ISI 75% UT No Recordable Pipe to Valve (therefore, no surface examination is performed). There was no Indications 2R10 (Spring 2004 examination coverage from the valve side and limited ultrasonic Outage) examination from the pipe side due to the configuration. See Figure RR-48 for picture.

E6-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-48 Version 1.0 FIGURE RR-48 Typical Single-Side Access for Volumetric Examinations E6-4

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 7 Relief Request RR-49 Reactor Pressure Vessel Shell and Bottom Head Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-49 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Units 1 and 2.

Interval-Interval Dates:

2nd ISI Interval - May 31, 1997 through May 30, 2007.

Requested Date 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by for Approval and the code or addenda is determined to be impractical by the licensee and Basis is not included in the revised inservice inspection program as permitted by paragraph (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 1, ASME Section XI Category B-A, Items B1.11, B1.12, and B1.21 Components Affected: reactor pressure vessel (RPV) welds, as shown in Table RR-49.

Applicable Code Edition and ASME Section XI, 1989 Edition with no addenda.

Addenda:

Applicable Code ASME Item numbers (B1.11 and B1.12) listed above for Table IWB-Requirements: 2500-1, Examination Category B-A, require that 100% of the length of each weld be examined. However, ASME Item numbers B1.21 listed above for Table IWB-2500-1, Examination Category B-A, requires that the accessible length of each weld be examined. Even though only the accessible length was required for Item B1.21 welds, they were conservatively included. Per Code Case N-460, coverage greater than 90% is acceptable. The examination volume is shown in ASME Section XI, Figure IWB-2500-1 for Item Number B1.11, Figure IWB-2500-2 for Item Number B1.12, and Figure IWB-2500-3 for Item Number B1.21.

Impracticality of Physical limitations due to the geometric configuration of the welded Compliance: areas restricted coverage of the examination volume as required by the figures. A total of seven RPV welds for Vogtle-1 and -2 are shown in Table RR-49. Three longitudinal welds on the Vogtle-1 RPV are included but the corresponding welds for Vogtle-2 did not have the limited examination. The design of the Vogtle-2 RPV included placing the core support lugs at different azimuths from the three lower shell longitudinal welds in order to maximize examination coverage. As noted in the limitations, additional positioning of the ultrasonic transducer was undertaken to maximize the coverage for these seven welds.

Appreciably increasing coverage was impractical due to the interferences described in Table RR-49.

E7-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-49 Version 1.0 Burden Caused Obtaining more coverage would require replacement of the Vogtle-1 and -

by Compliance: 2 reactor pressure vessels.

Proposed The examination of these seven welds was performed using automated Alternative and ultrasonic techniques qualified through the Appendix VIII process. A Basis for Use: large percentage of the weld root was interrogated for these seven welds and no ultrasonic indications exceeded the allowable flaw tables. In addition, VT-2 visual examinations are performed each refueling outage for these components. Based on these examination results plus the cumulative volumetric examination coverage of all RPV shell welds there is reasonable assurance of structural integrity and relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed The proposed relief request is applicable for the 2nd Interval.

Relief Request:

Precedents: These RPV welds were examined during the first ISI interval with less coverage and were documented to the NRC. The NRC granted approval for these limited examinations by letters dated January 29, 1999 for Unit-1 and June 5, 2000 for Unit-2.

References:

TAC Nos. MA0284 and MA3944 plus MA4356 Status: Awaiting NRC approval.

E7-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-49 Version 1.0 TABLE RR-49 Weld Number / ASME Examined Item Coverage Basis for Limited Coverage 11201-V6-001-W06 B1.11 78.4% The UT examination of this circumferential weld was limited by the proximity of six RPV core support lugs. Scanning was conducted between and below the obstructing lugs with the 1R13 (Fall 2006 scan boundaries maximized by visually-assisted positioning of the remote examination head Outage) so that the scan starts and stops were as close to the core support lugs as possible.

11201-V6-001-W18 B1.12 79.0% The UT examination of this longitudinal weld was limited by the proximity of RPV core support lug at the 60° azimuth location. Scanning was conducted in both the perpendicular 1R13 (Fall 2006 and parallel directions around the obstructing lug with the scan boundaries maximized by Outage) visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the core support lug as possible.

11201-V6-001-W19 B1.12 79.0% The UT examination of this longitudinal weld was limited by the proximity of RPV core support lug at the 180° azimuth location. Scanning was conducted in both the perpendicular 1R13 (Fall 2006 and parallel directions around the obstructing lug with the scan boundaries maximized by Outage) visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the core support lug as possible.

11201-V6-001-W20 B1.12 79.0% The UT examination of this longitudinal weld was limited by the proximity of RPV core support lug at the 300° azimuth location. Scanning was conducted in both the perpendicular 1R13 (Fall 2006 and parallel directions around the obstructing lug with the scan boundaries maximized by Outage) visually-assisted positioning of the remote examination head so that the scan starts and stops were as close to the core support lug as possible.

11201-V6-001-W07 B1.21 74.1% The UT examination of this circumferential weld was limited by the proximity of the peripherally-located bottom-mounted inspection (BMI) tubes. Scanning was conducted 1R13 (Fall 2006 between the obstructing tubes with the scan boundaries maximized by visually-assisted Outage) positioning of the remote examination head so that the scan starts and stops were as close to the BMI tubes as possible.

E7-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-49 Version 1.0 TABLE RR-49 Weld Number / ASME Examined Item Coverage Basis for Limited Coverage 21201-V6-001-W06 B1.11 78.4% The UT examination of this circumferential weld was limited by the proximity of six RPV core support lugs. Scanning was conducted between and below the obstructing lugs with the 2R12 (Spring 2007 scan boundaries maximized by visually-assisted positioning of the remote examination head Outage) so that the scan starts and stops were as close to the core support lugs as possible.

21201-V6-001-W07 B1.21 74.1% The UT examination of this circumferential weld was limited by the proximity of the peripherally-located bottom-mounted inspection (BMI) tubes. Scanning was conducted 2R12 (Spring 2007 between the obstructing tubes with the scan boundaries maximized by visually-assisted Outage) positioning of the remote examination head so that the scan starts and stops were as close to the BMI tubes as possible.

E7-4

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 8 Relief Request RR-50 Class 2 Vessel Weld Examinations

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-50 Version 1.0 Plant Site- Vogtle Electric Generating Plant - Units 1 and 2 Unit:

Interval- 2nd ISI Interval - May 31, 1997 through May 30, 2007 Interval Dates:

Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by Date for the code or addenda is determined to be impractical by the licensee and Approval and is not included in the revised inservice inspection program as permitted Basis by paragraph (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 2, ASME Section XI, Code Category C-B, Item No. C2.21, for Components Class 2 vessel welds as shown on Table RR-52.

Affected:

Applicable ASME Section XI, 1989 Edition with no addenda.

Code Edition and Addenda:

Applicable Table IWB-2500-1, Examination Category C-B, Item C2.21 requires Code examination per Figure IWC-2500-4(a), (b) or (c).

Requirements:

Impracticality Physical limitations due to geometric configuration of the welded areas of restricted coverage of the examination volume as required by the figures Compliance: referenced above. The five welds with limitations include the RHR heat exchanger (1205 system) and the Class 2 portion of the steam generator 4 (1201 system). The limitations are described in Table RR-

50. The ASME Code figures are not representative of the Vogtle RHR heat exchanger nozzle weld numbers W04 and W05. Figure RR-50-1 shows the Vogtle RHR heat exchanger nozzle configuration which includes the reinforcing plate on the ID of the nozzle as compared to the ASME Code Figure IWC-2500-4(c) which shows the reinforcing plate on the OD. Figure RR-50-2 shows the Auxiliary Feedwater Nozzle on Unit-2 steam generator 4. With this configuration, the examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing heat Caused by exchangers and steam generators with a special design to allow Compliance examination.

E8-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-50 Version 1.0 Proposed A surface examination was performed on these welds. The inspection Alternative volume of all five welds was interrogated with UT from one side of the and Basis for weld looking for circumferential cracking. In addition, VT-2 visual Use: examinations associated with the Class 2 leakage test are performed once an ISI period on all of these welds. These examinations and tests provide reasonable assurance that structural integrity is being maintained; therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of The proposed relief request is applicable for the 2nd ISI Interval.

Proposed Relief Request:

Precedents: The physical limitations described in this relief request are very similar to Vogtle RR-14, Revision 3 which was approved by the NRC on June 20, 2001.

References:

NRC SER TAC Nos. MB0603 and MB0604.

Status: Awaiting NRC approval.

E8-2

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-50 Version 1.0 TABLE RR-50 Weld Number / ASME Examination Examined Item Coverage Limitations Results 11205-E6-002-W04 C2.21 100% PT This is a stainless steel heat exchanger. Due to the configuration (see No Recordable 41.5% UT Figure RR-50-1), the axial scans looking for circumferential cracking Indications 1R12 (Spring were performed only from the nozzle side. Axial scan coverage from 2005 Outage) the nozzle side was complete; however, because the material is stainless steel, only 50% of the examination volume was conservatively credited for examination. There were limited circumferential scans looking for axial cracking due to the weld configuration. 100% surface examination performed.

11205-E6-002-W05 C2.21 100% PT This is a stainless steel heat exchanger. Due to the configuration (see No Recordable 41.5% UT Figure RR-50-1), the axial scans looking for circumferential cracking Indications 1R12 (Spring were performed only from the nozzle side. Axial scan coverage from 2005 Outage) the nozzle side was complete; however, because the material is stainless steel, only 50% of the examination volume was conservatively credited for examination. There were limited circumferential scans looking for axial cracking due to the weld configuration. 100% surface examination performed.

21205-E6-002-W04 C2.21 100% PT This is a stainless steel heat exchanger. Due to the configuration (see Code-allowable 41.5% UT Figure RR-50-1), the axial scans looking for circumferential cracking PT indication; 2R12 (Spring were performed only from the nozzle side. Axial scan coverage from No Recordable 2007 Outage) the nozzle side was complete; however, because the material is UT Indications stainless steel, only 50% of the examination volume was conservatively credited for examination. There were limited circumferential scans looking for axial cracking due to the weld configuration. 100% surface examination performed.

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SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-50 Version 1.0 TABLE RR-50 Weld Number / ASME Examination Examined Item Coverage Limitations Results 21205-E6-002-W05 C2.21 100% PT This is a stainless steel heat exchanger. Due to the configuration (see No Recordable 41.5% UT Figure RR-50-1), the axial scans looking for circumferential cracking PT Indications; 2R12 (Spring were performed only from the nozzle side. Axial scan coverage from Code-allowable 2007 Outage) the nozzle side was complete; however, because the material is UT indication stainless steel, only 50% of the examination volume was conservatively credited for examination. There were limited circumferential scans looking for axial cracking due to the weld configuration. 100% surface examination performed.

21201-B6-004-W26 C2.21 100% MT This is a carbon steel steam generator. Due to the configuration (see No Recordable 50% UT Figure RR-50-2), the axial scans looking for circumferential cracking Indications 2R10 (Spring were performed only from the vessel side. Axial scan coverage from 2004 Outage) the vessel side was complete. Circumferential scans looking for axial cracking were limited to the weld and vessel side. 100% surface examination performed.

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SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-50 Version 1.0 Figure RR-50-1 for RHR Heat Exchanger Nozzle Welds Figure RR-50-2 for Steam Generator 4 Nozzle Weld E8-5

Vogtle Electric Generating Plant - Units 1 and 2 Second 10-Year Interval Inservice Inspection Program Submittal of Relief Requests Enclosure 9 Relief Request RR-51 Class 2 Residual Heat Removal Heat Exchanger Shell Welds

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-51 Version 1.0 Plant Site-Unit:

Vogtle Electric Generating Plant - Units 1 and 2 Interval-Interval Dates:

2nd ISI Interval - May 31, 1997 through May 30, 2007 Requested 10 CFR 50.55a(g)(5)(iv) states: Where an examination requirement by Date for the code or addenda is determined to be impractical by the licensee and Approval and is not included in the revised inservice inspection program as permitted Basis by paragraph (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination is determined to be impractical. Hence, SNC is asking for approval as soon as possible in order to close-out the second ISI interval activities.

ASME Code Class 2, ASME Section XI, Code Category C-A, Item Number C1.10, for Components Class 2 vessel shell welds as shown in Table RR-51.

Affected:

Applicable Code Edition ASME Section XI, 1989 Edition with no addenda.

and Addenda:

Applicable Table IWB-2500-1, Examination Category C-A, Item C1.10 requires Code Requirements: examination per Figure IWC-2500-1.

Impracticality Physical limitations due to geometric configuration of the welded areas of restricted coverage of the examination volume as required by the figure Compliance: referenced above. The two welds with limitations are on the Residual Heat Removal (RHR) heat exchanger and are described in Table RR-51.

Figure RR-51 shows the typical representation of the limited weld examinations. The examinations were performed to the maximum extent possible. Appreciably increasing coverage was impractical due to the limitations described in the table.

Burden Compliance would require replacement of the existing RHR heat Caused by Compliance exchangers with a special design to allow examination.

Proposed At least 74% of the examination volume of each weld was interrogated Alternative using two beam directions looking for circumferential cracking.

and Basis for Additionally, at least 95% of the examination volume of each weld was Use: interrogated using one beam direction looking for circumferential cracking. In addition, VT-2 visual examinations associated with the Class E9-1

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-51 Version 1.0 2 leakage test are performed once an ISI period on all of these welds.

These examinations and tests provide reasonable assurance that structural integrity is being maintained; therefore, relief should be granted per 10 CFR 50.55a(g)(6)(i).

Duration of Proposed Relief The proposed relief request is applicable for the 2nd ISI Interval.

Request:

Precedents: The physical limitations described in this relief request are very similar to Vogtle RR-14, Revision 3 which was approved by the NRC on June 20, 2001.

References:

NRC SER TAC Nos. MB0603 and MB0604.

Status: Awaiting NRC approval.

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SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-51 Version 1.0 TABLE RR-51 Weld Number / ASME Examination Examined Item Coverage Limitations Results 11205-E6-002-W01 C1.10 55% UT No examination coverage from the flange side due to the configuration. No Recordable Limited clockwise and counterclockwise scans (for axial flaws) on the Indications 1R10 (Spring weld due to the weld configuration. See Figure RR-51 for coverage.

2002 Outage) 21205-E6-002-W01 C1.10 56% UT No examination coverage from the flange side due to the configuration. UT indications Limited clockwise and counterclockwise scans (for axial flaws) on the due to 2R09 (Fall 2002 weld due to the weld configuration. See Figure RR-51 for coverage. Geometry Outage)

E9-3

SOUTHERN NUCLEAR OPERATING COMPANY PROPOSED RELIEF REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

RR-51 Version 1.0 Figure RR-51 for RHR Heat Exchanger Shell Welds E9-4

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